EUROFER REACH position on Iron Ore Pellets and Sinter. 28 ...

28 October 2008
<strong>EUROFER</strong> <strong>REACH</strong> <strong>position</strong> on Iron Ore Pellets and Sinter
<strong>REACH</strong> Exemptions
Article 2(7)(b) of <strong>REACH</strong> states that “substances covered by Annex V, as registration
is deemed inappropriate or unnecessary for these substances and their exemption
from these Titles does not prejudice the objectives of this Regulations”. The
exemption under Annex V allows the substances listed to be removed from the duties
of Registration, Downstream Users and Evaluation requirements.
A substance which occurs in nature is defined in Article 3(39) of <strong>REACH</strong> as;
“Substances which occur in nature means a naturally occurring substance as such,
unprocessed or processed only by manual, mechanical or gravitational means, by
dissolution in water, by flotation, by extraction with water, by steam distillation or by
heating solely to remove water, or which is extracted from air by any means”.
Ores are listed under the exemptions of Annex V. Ores such as iron ore can be
classed as substances, which occur in nature. Within the draft guidance document to
Annex V 1 it does state however that, “when ores are processed or treated with
methods not mentioned in the definition of ‘substances which occur in nature’ the
final ‘product’ of the treatment can normally not be regarded as a substance which
occurs in nature and hence will need to be registered”.
Substances, which are naturally occurring and are not chemically modified, are
exempt as is written above. A definition of a ‘Not chemically modified substance’ is
as follows; “a substance whose chemical structure remains unchanged, even if it has
undergone a chemical process or treatment, or physical mineralogical
transformation, for instance to remove impurities”.
Production of Iron Ore Pellets
Depending on where the iron ore is located and mined, it's mineralogical make-up
will differ. Some ores are predominantly Magnetite (Fe3O4) and some are Haematite
(Fe2O3). Pellets would ideally be in the form of Fe2O3; generally pellets will contain
>80% Fe2O3 and some small amounts of Fe3O4.
If the iron ore fines are Fe2O3 and processed into pellets, then theoretically, no
chemical change will occur as Fe2O3 is still there at the end point of the pellet
production. However, the temperature in the pelletisation process is very high, so
chemical modification can’t be excluded.
1 European Commission, Brussels, 19 th May 2008, Draft Guidance for Annex V
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28 October 2008
If the iron ore fines are Fe3O4 and processed into pellets (at temperature), then
oxidation would almost certainly take place causing a chemical modification to take
place, forming Fe2O3 at the end point. This, according to the definitions as listed
above, is a chemical modification and therefore causes that particular Fe2O3
registration under <strong>REACH</strong> is required.
The additions within the pellets (e.g. olivine and bentonite) will not be chemically
modified.
Production of Sinter
Independent from the iron ore (magnetite or haematite), sinter typically contains about
5-15% FeO in the end (besides e.g. Fe, Fe2O3 and CaO), so reduction will always take
place. This is defined as a chemical modification and therefore requires registration
under <strong>REACH</strong>.
Conclusions
• Iron ore pellets: (pre-)registration is recommended, even if the source is
haematite.
• Sinter: chemical modification to form e.g. FeO has taken place, so
(pre-)registration is recommended.
"Important Notice: This <strong>position</strong> paper is intended as a supplement to the <strong>REACH</strong> Regulation and the
official <strong>REACH</strong> Technical Guidance Documents published by the European Chemicals Agency
(ECHA). It is provided as an advisory document and, as such, has no legal standing. Therefore, in
conjunction with this <strong>position</strong> paper, users are advised to consult Regulation EC 1907/2006 (for the
legally binding requirements of <strong>REACH</strong>) and the official <strong>REACH</strong> Technical Guidance Documents (for
detailed information on <strong>REACH</strong> implementation). It may also be appropriate to seek independent
legal advice on matters related to pre-registration and registration. While every effort has been made
to ensure the accuracy of this document, neither Eurofer nor the authors of this document accept
liability for its content or for the use which might be made of the information herein."
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